Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Clause 2(c) of the 2006 interest waiver/reduction scheme requires non-payment of tax to result from a jurisdictional High Court ruling that governed the taxpayer when advance tax was paid or the return was filed. A later ruling does not satisfy that condition, and waiver also requires prior payment of the principal income-tax demand. Challenges to the underlying interest liability cannot be pursued in proceedings confined to a waiver application. Interest under section 220(2) arises only after default in paying a demand served under section 156 within the prescribed period. Waiver rejection was sustained, while taxpayers may seek refund of excess section 220(2) interest if charged from the return-filing date.
Clause 2(c) of the 2006 interest waiver/reduction scheme requires non-payment of tax to result from a jurisdictional High Court ruling that governed the taxpayer when advance tax was paid or the return was filed. A later ruling does not satisfy that condition, and waiver also requires prior payment of the principal income-tax demand. Challenges to the underlying interest liability cannot be pursued in proceedings confined to a waiver application. Interest under section 220(2) arises only after default in paying a demand served under section 156 within the prescribed period. Waiver rejection was sustained, while taxpayers may seek refund of excess section 220(2) interest if charged from the return-filing date.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
